CCTV Policy. In this section, we give you further information about us as a data controller.

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1 CCTV Policy 1. Data Controller In this section, we give you further information about us as a data controller. Page Dublin & Dún Laoghaire ETB is the data controller. Our address and contact details are DDLETB, 1 Tuansgate, Belgard Square East, Tallaght, Dublin 24. DDLETB is established under section 8 Education and Training Boards Act DDLETB provides primary level education, secondary level education, second chance education; further education and training including apprenticeships; Youthwork, community-based education programmes; prison education, outdoor education; outreach programmes, specialist programmes e.g. through Music Generation and other programmes/courses as maybe delivered/funded/sponsored in whole or part or in co-operation with other bodies/agencies etc. Our core functions are set out in section 10 Education and Training Boards Act 2013, together with such other matters as are set out in the Education and Training Boards Act 2013, together with such other legal and statutory obligations as may be imposed on the ETB from time to time. 1.2 DDLETB has developed this CCTV Policy to supplement the CCTV Privacy Notice and the ETB Data Protection Policy. This is in order to be transparent and accountable to data subjects in relation to the processing of CCTV data. 1.3 In this CCTV Policy, defined terms shall refer to those definitions used in section 1 of the DDLETB Data Protection Policy. 2. CCTV recordings and legal basis 2.1 This CCTV Policy applies to the premises owned or controlled by DDLETB. For the avoidance of any doubt, this Policy has no application to premises not in the ownership or control of ETB (e.g. external institutions, prisons, etc.). 2.2 In this section, we give you more information about the type of CCTV image we collect, why we use CCTV and what we do with CCTV recordings/images, and the lawful basis relied upon. 2.3 We use CCTV (video only, no audio/sound-recording) on our premises, at internal and external points. CCTV cameras are mounted on fixed-points, with no auto-tracking capabilities. 2.4 For the avoidance of doubt, CCTV monitoring/profiling of an individual based on any of the following characteristics is prohibited by this Policy: Age Civil status Disability Family status Gender Membership of the Traveller Community Race Religion Sexual orientation Membership of the Travelling Community. 2.5 CCTV will be utilised in a fair and ethical manner. The location of cameras is a key consideration. Use of CCTV to monitor areas where individuals would have a reasonable expectation of privacy (e.g. bathrooms, changing rooms, etc.) is considered by DDLETB to be unjustifiable and unethical.

2 2.6 DDLETB has endeavoured to select locations for the installation of CCTV cameras which are least intrusive to protect the privacy of individuals. Cameras placed so as to record external areas are positioned in such a way as to prevent or minimise recording of passers-by or of another person's private property. 2.7 In any area where CCTV is in operation, there will be a prominent sign displayed notifying people of same. For the avoidance of any doubt, there shall be no covert CCTV recording. 2.8 A data protection impact assessment (DPIA) is undertaken when installing or making adaptations to CCTV systems where the processing is likely to result in a high risk to the rights and freedoms of data subjects. Page The purposes of CCTV and the legal basis of same are set out below: Purposes 1. For security: (a) To deter unauthorised access to the ETB s property (b) To protect the ETB buildings and assets (including but not limited to files and data relating to our students and staff) both during and after school hours; (c) To capture images of those perpetrating criminal offences on the premises, including in the carparking areas, main entrance, exit gates etc (including intruders or individuals damaging property or removing items without authorisation) so that the recordings can be passed to An Garda Síochána, and used for criminal prosecutions; (d) To support An Gardaí Síochána and other civil authorities to detect and deter crime, and to identify, apprehend, and prosecute offenders; (e) To reduce the incidence of crime and anti-social behaviour (including theft and vandalism); (f) To provide a sense of security and safety to the School s students, parents, staff, service-providers, and visitors to its premises. (g) To monitor activity in the areas where cash is received from and receipted to students and/parents and/or where goods are received from couriers and/or service providers (Reception); (h) The monitoring of access control systems: to monitor and record restricted access areas at entrances to buildings and other areas; (i) verification of security alarms: Intrusion alarms, exit door controls, external alarms; Legal basis interests: to prevent and/or detect fraud, theft and crime, to ensure that the ETB adequately protects property and assets purchased/financed/maintained from funds provided by the Oireachtas. Legal obligation: ETB s duty of care to its students, staff, and visitors to its premises. Vital interests: the processing is necessary in order to protect the vital interests of the data subject or of another natural person. Prevention, investigation and detection of offences per Article 23(1)(d)GDPR: the prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including the safeguarding against and the prevention of threats to public security.

3 2. To uphold ETB policies/procedures to promote safety and well-being: (a) To ETB rules and policies are respected so that the ETB can be properly managed. (b) To deter any instances of bullying, harassment, and/or all other forms of unwanted and/or inappropriate behaviour. (c) To ensure that the ETB Code of Behaviour and Anti-Bullying Procedures and all other relevant policies are implemented so that the ETB can be properly managed; For the avoidance of any doubt, this means that CCTV footage may be used as part of any ETB procedure, including but not limited to a disciplinary, suspension, or expulsion process under the Code of Behaviour. This means that the CCTV footage may be viewed by the board of management, and the board of the ETB, together with any relevant external appeals bodies (e.g. Section 29 Appeal body) relevant to a suspension or expulsion process. 3. For verification and dispute-resolution purposes, particularly in circumstances where there is a dispute as to facts and the recordings may be capable of resolving that dispute. Legal obligation: ETB s duty of care to its students, staff, and visitors to its premises; the Safety Health and Welfare at Work Act 2005, to implement the Code of Behaviour adopted pursuant to section 23 Education (Welfare) Act 2000, and (where CCTV is relevant to a Code of Behaviour process) to facilitate the hearing of Appeals pursuant to section 29 Education Act 1998 (suspension, expulsion, etc). Where a parent makes a section 29 Appeal, and the internal ETB process is exhausted, by progressing with the appeal the parent acknowledges and understands that the personal data relating to them/their child shall be transferred by the ETB to the Department of Education and Skills for the purposes of their administering the appeal, convening the section 29 hearing etc. Vital interests: the processing is necessary in order to protect the vital interests of the data subject or of another natural person. interests: to maintain discipline and good order, to ensure that other students do not have their learning seriously disrupted by misbehaviour of other students, to ensure that other students and staff are not exposed to risks to their health and safety (including causing distress, anxiety, or any threat to physical safety). To prevent and/or detect fraud, theft and crime, to ensure that the ETB adequately protects property and assets purchased/financed/maintained from funds provided by the Oireachtas. interests: to prevent and/or detect fraud, to ensure that facts can be objectively verified to avoid disputes leading to costly litigation. For dispute resolution and litigation purposes. Page 3

4 4. For litigation purposes. interests: to ensure that all relevant data is available for litigation purposes, to ensure the effective administration of justice. 5. For verification and dispute-resolution purposes as part of any investigation (including external investigations, e.g. Teaching Council, TUSLA, An Garda Síochána). Legal Obligation: depending on the nature of the request, this may include a request from external agencies as part of external investigations, e.g.: Child Protection matter - Section 16 Children First Act 2015 TUSLA may require ETB to assist TUSLA and if the ETB furnishes any information (including a report), document or thing to the Agency pursuant to a request made under subsection (1), the furnishing of that information, document or thing shall not give rise to any civil liability in contract, tort or otherwise and nor shall the information, document or thing be admissible as evidence against that person in any civil or criminal proceedings. Teaching Council inquiry section 43B Teaching Council Acts : a person commits an offence where he or she [ ] (b)refuses [ ](ii) to produce any document 1 in his or her power or control lawfully required by the panel to be produced by him or her. National security, law enforcement or criminal investigation matters - An Garda Síochana: per Article 23(1)(d)GDPR: the prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including the safeguarding against and the prevention of threats to public security. Page 4 Vital interests: the processing is necessary in order to protect the vital interests of the data subject or of another natural person. interests: to prevent and/or detect fraud, theft and crime, to ensure that the 1 Defined in section 43(19)(d) (as amended) as including any audio or video recording.

5 ETB adequately protects property and assets purchased/financed/maintained from funds provided by the Oireachtas. Page 5 This is an indicative, non-exhaustive list. We will utilise CCTV for purposes not necessarily listed here provided there is a legal basis, and/or we are legally required to do so. Section 3: Recipients of CCTV recordings 3. We share and transfer CCTV recordings data to other data controllers. In this section we give you further information about the recipients or categories of recipients of the personal data. 3.1 Parents/guardians: Where the student is under 18 years, we may show CCTV footage to the student s parent/guardian (for example, as part of a Code of Behaviour process that may lead to the student s expulsion or suspension) if the images can be appropriately redacted/pixelated to protect the personal data of third parties. 3.2 An Garda Síochána: for the investigation, detection and prevention of offences. 3.3 To social workers, HSE, and/or TUSLA: in respect of any child protection and/or child safeguarding and/or child welfare matters. 3.4 Student Support Team/Pastoral Care Team: (for further information, please see section 3.3 of DDLETB Data Protection Policy): to support the School s non-violent crisis intervention programme and as part of any post-event reflective training for staff to reinforce techniques and strategies of verbal and non-verbal de-escalation where challenging behaviour is exhibited by a student. These CCTV recordings may be used by and viewed by the Student Support team/pastoral Care team in the following ways: a) To conduct a post-crisis review to develop improved prevention strategies; b) To review performance and techniques with a view to attaining better outcomes in the future; c) To support positive behaviour from our students and reinforcing the Code of Behaviour; d) To inform a student s Individual Educational Plan and any care programmes in place for that student. e) To reduce the risk of future incidents or injuries, f) To assist the staff and clinical support personnel working with the student in developing appropriate care programmes best suited to that individual student. 3.5 Department of Education and Skills and/or any section 29 Appeals Committee: in relation to any Code of Behaviour, suspension and/or expulsion process. 3.6 Teaching Council: where we are legally required in relation to any process under the Teaching Council Acts , including fitness to teach investigation. 3.7 ETBs Insurer and/or Legal Advisors, including the Legal Services Support Unit, Education and Training Boards Ireland: the ETB transfers and shares CCTV recordings with its insurers, Irish Public Bodies, and their duly appointed workplace investigators, claims handlers etc. The ETB also shares/transfers CCTV data to its ETB legal advisors. These transfers are for the purposes of obtaining legal advices, resolving disputes, and defending,

6 compromising or otherwise settling litigation. CCTV data may also be transferred to the Health & Safety Authority when investigating workplace accidents. 3.8 CCTV administrators and IT support: to assist us with the administration and maintenance of the CCTV system and associated hardware and software. 3.9 Other parties: where you give your consent or instruct us to do so (e.g. to your solicitor, to your union representative etc), or where we are otherwise legally required (e.g. a Court Order). Page 6 Section 4: Third country/international transfers We do not transfer your personal data to a third country or international organisation. Section 5: Automated decision making/profiling We do not engage in ADM/profiling. Section 6: Records Retention For further information about the period for which CCTV is retained (or if that is not possible, the criteria used to determine that period), please refer to Section 6 of the DDLETB Data Protection Policy. Section 7: Your rights You have the following statutory rights that can be exercised at any time: (a) Right to information. (b) Right to complain to supervisory authority. (c) Right of access. (d) Right to rectification. (e) Right to be forgotten. (f) Right to restrict processing. (g) Right to data portability. (h) Right to object and automated decision making/profiling. For further information, please see section (7) of our Data Protection Policy available at or alternatively contact our DPO. Section 8: Contact our DPO We have appointed a Data Protection Officer (DPO) on an interim basis, Paddy Lavelle can be contacted at dataprotection@ddletb.ie. If you have any queries, please consult our Data Protection Policy (available at or contact our DPO.